Effective as of 28 February 2023, Ukraine introduced three sets of personal sanctions against 277 individuals and 92 legal entities in total.[1]

The Decisions sanctioned the following persons:[2]

  1. Those involved in the abduction and illegal trafficking of Ukrainian children to Russia, in particular:
    • Russian children’s rights officials — Igor Morokov, Kseniia Mishonova, Anna Mitianina, Svetlana Adamenko, Ekaterina Smoroda, Danilo Trubitsyn, etc.
    • Russian charitable and humanitarian organizations — Charitable Foundation for Helping People in Difficult Life Situations “Gulfstream”, All-Russian Public Movement “National Front ‘For Russia'”, Autonomous Non-Commercial Organization for the Support of Humanitarian Programs “Russian Humanitarian Mission”, All-Russian Non-Government Organization “Russian Red Cross”, Autonomous Non-Profit Organization “Home for Mommy”, etc.
  2. Those helping maintain mercenary groups in Russia involved in the war against Ukraine, in particular:
    • Individuals related to companies ensuring the operation of Russian militants, especially Private Military Company “Wagner” — Ekaterina Prigozhina, Veronika Prigozhina, Polina Prigozhina, Andrei Troshev, Dmitrii Utkin, Pikalov Konstantin, etc.
    • Russian and foreign legal entities related to companies supporting the operation of Russian militants, especially Private Military Company “Wagner” — LLC “Concord Management and Consulting” (Russia), JSC “ChVK Vagner tsentr” (Russia), LLC “Concord M” (Russia), LLC “M Invest” (Russia), Sewa Security Services (Central African Republic), Changsha Tianyi Space Science and Technology Research Institute Co. Ltd (Spacety Co. Ltd) (China), Shine Dragon Group Limited (Hong Kong SAR China), etc.
  3. Representatives of the Russian sports sector who are trying to use sports at the service of the Russian aggression, in particular: Russian sportsmen and a sportswoman — Elena Isinbaeva, Aleksandr Popov, Vitalii Smirnov, Shamil Tarpishchev.

The Decisions impose extensive sanctions, including but not limited to asset freezes; restrictions on the exit of capital from Ukraine; suspension of the performance of economic and financial obligations; and prohibition on the transfer of technologies and on the rights to objects of intellectual property rights.

The full lists of individuals and legal entities subject to sanctions are set forth in the annexes to the Decisions

Any party dealing with persons on the sanctions lists must carefully assess the exact scope of the sanctions imposed and the implications of dealing with such entities and individuals.


[1] Presidential Decree No. 114/2023 dated 26 February 2023, “On the Decision of the National Security and Defense Council dated 26 February 2023 ‘On Imposing of Personal Special Economic and other Restrictive Measures (Sanctions)'”, Presidential Decree No. 115/2023 dated 26 February 2023, “On the Decision of the National Security and Defense Council dated 26 February 2023 ‘On Imposing of Personal Special Economic and other Restrictive Measures (Sanctions)'”, Presidential Decree No. 116/2023 dated 26 February 2023, “On the Decision of the National Security and Defense Council dated 26 February 2023 ‘On Imposing and Amending of Personal Special Economic and other Restrictive Measures (Sanctions)'”, effective from 28 February 2023 (together, “Decisions“).

[2] Address of President of Ukraine Volodymyr Zelenskyy dated 26 February 2023.

Author

Hanna Shtepa is a Counsel heading the International Commercial & Trade (ICT) practice in the Kyiv office of Baker McKenzie. The practice is ranked Tier 1 by Legal 500 EMEA. She specializes in international trade restrictions, economic sanctions and export controls compliance, structuring international supplies of goods and services, anti-dumping investigations, public procurement regulations, trade and general compliance, legal regime and restrictions related to temporary occupied territories and business operations during the military state. She also has extensive experience in project finance, focusing on renewable and conventional energy, financial restructuring, sovereign and municipal finance, nuclear liability. Hanna is ranked as Next Generation Partner for International Trade and Energy and recommended as a Rising Star in Banking, Finance and Capital Markets by Legal 500 EMEA 2020-2022. Ms. Shtepa holds her LL.M. in International Commercial Arbitration Law from the Stockholm University, Stockholm, Sweden.